Comment on DOD-2008-OS-0124-0001

I am interested in the SAPR interim rule because I am a certified sexual assault advocate. The issue is whether the proposed policy changes in the SAPRO manual, pursuant to 32 CFR Part 103, will provide a more accurate number of reported sexual assault incidents that occur while serving in the military. More specifically, the issue is whether the rule will effectively address potential problems that may keep certain types of people from wanting to report a sexual assault incident. This rule is certainly a step in the right direction to effectively combat incidences of sexual assault in the military. Is it enough? Absolutely not. The proposed rule does not change the fact that a commanding officer is in charge of adequately staffing at SAPRO installations near combat zones. A staggering 63% of reported service member victims in 2010 were women between the ages of 18-22 in the lowest ranks (E1-E4) . As reported in the FY10 annual report, just in the Navy alone, 69 out of 325 service member victims declined to participate in any judicial action. Id at 397. The trend indicates that there is a decrease in the number of reported incidents and investigation. Id. Although restricted reporting prevents a commanding officer from being provided with a name of the victim, the commanding officer is still told of an assault for safety reasons. Id. The commanding officer will likely find out the name of the victim. Therefore, this proposed rule does not change the reason why so many people chose not to report. Id. Victims choose not to report out of fear that they will not be believed, concerns about privacy, shame and blame associated with the crime, and belief that police can’t do anything about the crime. As reported in the 2010 Dr. Whitley SAPRO presentation, it is well understood that reporting one’s own victimization and seeking help are mistakenly believed to go against the strength, honor, and courage inherent in military values .